• Proposal: The proposed construction of a barge house large enough to
house the barge, store equipment and provide display and
education opportunities including a replacement café ;
wetdock with a guillotine sluice gate to hold water at mean
high water so that the barge can be displayed to the public and
a dredged channel to enable access when river is at the
retained level of 1.7m AOD
• Location: Orleans Road, Twickenham, TW1 3BL.
Thank you for consulting us at the pre-application stage. We welcome proposals
which “make space for water” and restore more natural environmental processes
which can deliver multiple environmental, social and economic benefits.
Having reviewed the proposal we would like to highlight the following issues and
opportunities for this key riverside park. These are related to: Flood risk management,
Flood defences and climate change; and Biodiversity and fisheries
• Flood risk management
The site is located in the highest risk zone called Flood Zone 3 in front of the
Thames Tidal Defences. As such it could be considered to be functional flood
plain (FZ3b). The proposal is classified and water compatible (barge house) and
less vulnerable (cafe) in Table 2: Flood risk vulnerability classification of the
Technical Guidance to the National Planning Policy Framework.
Table 1: Flood zones sets out the suitability of certain type of development within
areas of flood risk. Water compatible development is classed as appropriate
development in flood zone 3B, however less vulnerably development is classified
as unsuitable at this location. In this case the less vulnerable element will be a
replacement café on a like for like footprint and so would not be
increasing/introducing new risk into the functional flood plain so we would have no
objection. In order for the proposal to be acceptable in its current form you should
discuss the issue of functional flood plain with Richmond Local Planning authority.
If the proposal were to progress to a planning application then you would need to
produce a Flood Risk Assessment (FRA). The FRA should be prepared in
accordance with the Technical Guidance to the NPPF. Much of the information
required to inform the assessment may be obtained from the London Borough of
Richmond‟s Strategic Flood Risk Assessment (SFRA), which shows local flood
risk at a strategic level.
Your FRA should include the following:
– Identification of the Flood Zone and vulnerability classification in accordance
with Table 2 of the Technical Guidance to the NPPF.
– Confirmation of the flood defences and standard of protection provided, to
confirm the level of residual risk in accordance with the SFRA for the borough.
– Estimation of flood depths at the site for a range of flood events, to calculate
internal flood depths in the event of a flood event.
– Suitable flood mitigation measures based on flood characteristics at site.
We recommend that you use flood resistance and resilience measures and
construction techniques to help reduce the impact of flooding should it occur.
Please refer to “Improving the Flood Performance of New Buildings: Flood
Resilient Construction” (CLG, 2007).
You may also wish to consider whether a Flood Warning and Evacuation Plan
would assist in reducing the impact of flooding on the future users of the
development. We do not normally comment on or approve the adequacy of flood
emergency procedures accompanying development proposals, as we do not
carry out these roles during a flood. Our involvement with this development during
an emergency will be limited to delivering flood warnings to occupants/users
covered by our flood warning network.
Paragraph 9 of the Technical Guidance to the NPPF states that those proposing
developments should take advice from the emergency services when producing
an evacuation plan for the development as part of the flood risk assessment. In all
circumstances where warning and emergency rs is fundamental to managing
flood risk, we advise local planning authorities to formally consider the emergency
planning and rescue implications of new development in making their decisions.
Our Customers and Engagement Team can provide any relevant flooding
information that we have available. Please be aware that there may be a charge
for this information. Please contact 01707 632 511 or email:
• Climate change and Thames Estuary 2100 (TE2100)
As the development is within the floodplain you will need to consider TE2100
advice. An assessment should be made on the implications that rising water
levels due to climate change would have on the development and how the flood
defences can be raised if required. We recommend discussing the proposed
works to the flood defences in this area with London Borough of Richmond upon
Thames and how it fits with the wider long term management of flood defence
structures in Richmond and Twickenham.
More information can be found at:
• Flood defences
Its essential the level of flood defence protection is maintained for this area of
high risk and regular flooding at high tides. We have concerns on the potential
negative impacts of reinstating the subway from Orleans House Gallery to the
barge house. We recommend that an alternative form of access is considered or
we agree ways to maintain flood defences
Under the terms of the Water Resources Act 1991, and the Thames Land
Drainage Byelaws 1981, the prior consent of the Environment Agency is required
for any proposed works or structures, in, under, over or within 16 metres of the
landward edge of the tidal defence of the River Thames, designated a „main
• Water Framework Directive
The Water Framework Directive (WFD) came into force in 2000 and is the most
substantial piece of EU water quality legislation to date. The Thames River Basin
Management Plan was produced in 2009 to provide an initial guide on how the
targets for water quality improvements as set out in the WFD could be met for this
catchement. All new activities in the water environment will need to take the
Directive and the river basin management plan into account.
A fundamental requirement of the Water Framework Directive is to attain good
ecological water quality status and that deterioration in the status of waters is
prevented. Any new development must ensure that these two fundamental
requirements of the Directive are not compromised.
As your development involves bank and in channel works you should investigate
if a WFD assessment is required. WFD assessments aim to determine the effects
of proposed schemes on ecological quality, identifying any potential impacts that
could cause deterioration in the status of a water body or could hinder the water
body from meeting its WFD objectives. More information can be found at
• Biodiversity and fisheries
Please refer to “Rivers by Design” which provides a useful guide for planners,
designers and developers, providing practical advice and information on restoring
and protecting rivers and sharing good practice case study examples of projects
that have been successfully implemented across Europe. This available from:
http://www.restorerivers.eu/ Due to the developments location and the potential for
work in the River Thames you should produce an environmental assessment to ensure
there is no risk to wildlife and look at ways to improve the riverside environment for people
and wildlife. We will also require a method statement setting detailing any in channel
works and how the impact on fish and aquatic biodiversity will be mitigated.
• Advice for developers
We have updated our advice for developers and it is now a joint agency
document with advice from Environment Agency, Natural England and Forestry
Commission, it‟s available to view on our website
I trust hope our response is helpful and we look forward to working with you on
this exciting project. We are happy to review any draft reports prior to formal
submission. If you require any additional information please contact me . .
Sustainable Places – Planning Advisor